Modern Slavery and Human Trafficking Statement and Policy.

Guardian Care Group Limited is committed to conducting its business ethically, responsibly and with respect for the dignity and human rights of every person.

We have zero tolerance for modern slavery, human trafficking, forced or compulsory labour, servitude, child labour, debt bondage or any other form of exploitation within our organisation or supply chains.

We are committed to complying with the Modern Slavery Act 2015 and to upholding Article 4 of the European Convention on Human Rights, concerning the prohibition of slavery and forced labour.

We will work openly and collaboratively with commissioners, local authorities, regulators, employees, workers, suppliers and other stakeholders to identify, prevent and address modern slavery risks.

Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations with annual turnover of £36 million or more to publish an annual slavery and human trafficking statement.

Guardian Care Group Limited does not currently meet that turnover threshold and is therefore not legally required to publish an annual statement under Section 54.

Nevertheless, Guardian has voluntarily adopted and published this Statement and Policy to demonstrate its commitment to preventing modern slavery and exploitation within its operations and supply chains. We will review it annually and will comply fully with the statutory reporting requirements if Guardian becomes subject to Section 54 in the future.

Guardian Care Group Limited is an emerging care and community-support provider based in Greater Manchester.

Our developing services include person-centred social care, community support, companionship, meaningful activities, community access, carer respite and associated support services. Guardian will only undertake services for which it has the necessary competence, workforce, approvals and regulatory status.

Our people and supply chain may include:

• Directly employed staff and workers.
• Temporary and agency workers, where required.
• Training and professional-development providers.
• Recruitment and background-checking services.
• Information technology and telecommunications providers.
• Office, facilities and professional-service providers.
• Insurance, payroll and financial-service providers.
• Transport and equipment suppliers.
• Suppliers of uniforms, personal protective equipment and other workplace materials.
• Approved subcontractors, should subcontracting be required.

Guardian does not currently operate a complex international supply chain. However, we recognise that modern slavery risks can exist at any level of a supply chain, including in recruitment, agency labour, transport, cleaning, clothing, technology, equipment and other purchased goods and services.

This policy applies to:

• Directors and senior managers.
• Employees, workers and volunteers.
• Agency and temporary personnel.
• Consultants and contractors.
• Suppliers and subcontractors.
• Any other person or organisation working for or on behalf of Guardian.

All persons working with Guardian are expected to act honestly and ethically and to report any concern relating to modern slavery or exploitation.

Guardian's approach to preventing modern slavery is supported by its wider governance arrangements, including policies and procedures covering:

• Safer recruitment.
• Safeguarding adults and children.
• Whistleblowing and speaking up.
• Equality, diversity and inclusion.
• Dignity at work.
• Health and safety.
• Grievances and complaints.
• Recruitment and selection.
• Right-to-work verification.
• Procurement and supplier management.
• Disciplinary procedures.
• Data protection and confidentiality.
• Incident reporting and escalation.

These policies will be reviewed periodically and updated as Guardian's services and workforce develop.

Guardian is committed to fair and ethical recruitment.

Before appointing workers, Guardian will undertake appropriate pre-employment checks, including:

• Verification of identity.
• Right-to-work checks.
• Employment-history checks.
• References.
• Appropriate Disclosure and Barring Service checks.
• Verification of relevant qualifications and professional registrations.
• Assessment of suitability, values and competence for the role.

Guardian will not knowingly:

• Charge workers recruitment fees as a condition of obtaining work.
• Use recruitment organisations that charge prohibited or exploitative worker-paid fees.
• Retain passports, identity documents or bank cards.
• Require workers to surrender control of their wages.
• Use threats, coercion, deception or intimidation.
• Restrict a worker's lawful freedom of movement.
• Permit forced or compulsory overtime.
• Tolerate discrimination, harassment, victimisation or retaliation.
• Prevent workers from joining or participating in a lawful trade union.

Workers will be provided with clear information about their role, pay, hours and employment status. Guardian will seek to ensure that wages are paid directly and transparently and that deductions are lawful and properly explained.

Guardian recognises that potential modern slavery risks may arise through:

• The use of temporary or agency labour.
• Recruitment involving overseas candidates or labour intermediaries.
• Workers who may have limited English-language skills.
• Workers whose immigration status makes them vulnerable to exploitation.
• Undisclosed recruitment fees or personal debt.
• Excessive control by another person over a worker's travel, documents, wages or accommodation.
• Subcontracted or outsourced services.
• Low-cost goods manufactured through extended or international supply chains.
• Sudden changes in a worker's behaviour, appearance, attendance or financial circumstances.
• Workers being transported, housed or paid by an unknown third party.
• Unexplained reluctance to speak without another person present.

Risks will be assessed proportionately according to the nature of the service, workforce, supplier, country of origin and supply chain involved.

Guardian expects suppliers and subcontractors to comply with the Modern Slavery Act 2015 and all applicable employment, equality and human-rights legislation.

Before engaging a material or higher-risk supplier or subcontractor, Guardian may:

• Review the organisation's identity, ownership and trading status.
• Request its modern slavery statement or relevant employment policy.
• Examine its recruitment and employment practices.
• Ask how it manages modern slavery risks in its own supply chain.
• Check relevant professional registrations, accreditations and insurance.
• Seek contractual assurances regarding modern slavery compliance.
• Request evidence of worker checks, training and safeguarding arrangements.
• Conduct proportionate monitoring, audits or other due-diligence activity.

Guardian will require subcontractors supporting public-sector contracts to maintain appropriate policies addressing modern slavery and ethical working practices.

Where concerns are identified, Guardian will work with the supplier, commissioner or relevant authority to agree an appropriate corrective-action plan. Serious, deliberate or unresolved breaches may result in suspension or termination of the relationship and referral to the appropriate authorities.

Suppliers and subcontractors must:

• Comply with the Modern Slavery Act 2015 and other applicable legislation.
• Prohibit forced labour, servitude, human trafficking and child labour.
• Maintain fair and lawful recruitment and employment practices.
• Ensure workers retain control of their identity documents.
• Ensure wages and deductions comply with the law.
• Allow workers to raise concerns without fear of retaliation.
• Respect workers' freedom of association and right to join a trade union.
• Cooperate with proportionate investigations, audits and due-diligence exercises.
• Notify Guardian promptly of suspected or confirmed modern slavery.
• Take appropriate remedial action where shortcomings are identified.
• Apply equivalent standards within their own supply chains.

Guardian reserves the right to refuse, suspend or terminate arrangements where a supplier or subcontractor fails to meet these expectations.

Employees, workers, volunteers, suppliers and subcontractors are encouraged to raise concerns at the earliest opportunity.

Concerns may include a suspicion that:

• A person is being forced or coerced to work.
• A person's passport, wages or bank card is being controlled by someone else.
• Recruitment fees or debts are being used to control a worker.
• A worker is being threatened or prevented from leaving employment.
• A worker appears to be trafficked or otherwise exploited.
• A supplier is failing to protect its workers.

Concerns should normally be reported to a manager, safeguarding lead or director. They may also be raised through Guardian's whistleblowing arrangements.

Reports will be treated seriously and handled sensitively. Guardian will not tolerate retaliation or detrimental treatment against anyone who raises a genuine concern in good faith.

Where there is an immediate danger, the emergency services should be contacted. Guardian will make appropriate safeguarding referrals and cooperate with the police, local authority, National Crime Agency, National Referral Mechanism or other responsible body where required.

Where potential modern slavery is identified, Guardian will prioritise the safety, dignity and welfare of the person affected.

Guardian will:

1. Take immediate action where a person is at risk of harm.
2. Notify the designated safeguarding lead or a director.
3. Preserve relevant information and records.
4. Avoid confronting suspected perpetrators where doing so could increase risk.
5. Seek specialist or statutory advice.
6. Make appropriate safeguarding and criminal-justice referrals.
7. Cooperate fully with any investigation.
8. Consider the need to suspend a worker, supplier or subcontractor while enquiries take place.
9. Develop corrective and preventative actions.
10. Review what happened and strengthen relevant controls.

Decisions will be made using a victim-centred and proportionate approach. Guardian will avoid action that could unintentionally expose a potential victim to further harm.

Relevant workers will receive information or training appropriate to their roles. This will include:

• Understanding what modern slavery and human trafficking mean.
• Recognising indicators of exploitation.
• Safer recruitment and right-to-work responsibilities.
• Ethical procurement and supplier risks.
• How to raise a concern.
• Whistleblowing protection.
• Safeguarding and escalation procedures.
• Recording and reporting responsibilities.

Additional training will be provided to directors, managers, recruitment staff and employees involved in procurement, supervision or safeguarding.

Guardian will monitor the effectiveness of this policy through proportionate measures, which may include:

• Completion of modern slavery and safeguarding training.
• Completion of required identity, right-to-work and recruitment checks.
• Assessment of new material or higher-risk suppliers.
• Number and nature of concerns raised.
• Time taken to investigate and respond to concerns.
• Completion of agreed corrective actions.
• Supplier compliance and due-diligence findings.
• Employee awareness assessed through supervision, audit or staff feedback.
• Annual review of this policy and the organisation's risk assessment.

As Guardian grows, these measures will be developed into formal performance indicators and reported to the Board.

When delivering public-sector contracts, Guardian will:

• Cooperate fully with proportionate investigations, vetting, assessments and due-diligence exercises.
• Provide relevant information about its supply chain when lawfully requested.
• Work collaboratively with commissioners to mitigate and reduce modern slavery risks.
• Address identified weaknesses through agreed improvement actions.
• Comply with applicable responsible-procurement, ethical-employment and sustainable-working expectations.
• Accept that serious or persistent non-compliance may lead to contractual sanctions or termination.
• Cooperate with appropriate referrals to safeguarding bodies, the police or the National Referral Mechanism.

Guardian will apply these commitments regardless of its turnover.

The Board of Directors has overall responsibility for:

• Approving this Statement and Policy.
• Promoting an ethical organisational culture.
• Ensuring appropriate systems and resources are available.
• Reviewing serious concerns and investigation findings.
• Monitoring compliance and improvement actions.
• Reviewing this Statement and Policy annually.

Managers are responsible for implementing the policy within their areas of work.

Every person working for or on behalf of Guardian is responsible for remaining alert to modern slavery risks and reporting concerns promptly.

Any employee who breaches this policy may be subject to disciplinary action, which may include dismissal for gross misconduct.

Guardian may terminate its relationship with a supplier, contractor or other third party that fails to meet the standards set out in this policy or refuses to implement required improvements.

This Statement and Policy will be reviewed at least annually and sooner if:

• Guardian's activities or supply chains materially change.
• A modern slavery concern or incident occurs.
• Relevant legislation or statutory guidance changes.
• A commissioner, regulator or responsible authority requires an update.

This Statement and Policy has been approved by the Board of Directors of Guardian Care Group Limited.